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Hawk Training | Modern Slavery Policy for financial year 2022/2023

1.0 Purpose

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Hawk Management (UK) Limited, trading as Hawk Training has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Hawk Training has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Established in 1989, Hawk Training is an Ofsted 'Outstanding' training provider specialising in apprenticeships. We are passionate about developing people and organisations. Our flexible and innovative approach to delivery is a key strength.

We will work in partnership with you to establish your learning and development strategy, skills gaps of specific staff demographics and budgets to allow us to tailor a programme of delivery to meet your needs. Using cutting edge technology enables us to provide a bespoke service which is cost effective and can take place anytime, anywhere.

 Hawk Training has not identified any areas of its direct business where there is a high risk of modern slavery, however we do acknowledge through the diverse range of customers we engage with and the recruitment and placement of learners onto apprenticeship programmes there is risk of these customers being involved in Modern Slavery. Our steps to mitigate this risk is through:

1. Embedding training to our apprentices and their employers through our British Values training activity, a mandatory component of every apprenticeship programme that we deliver.  
2. A whistleblowing policy for both staff and apprentices that includes Modern Slavery.

4.0 Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Safer Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
2. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
3. Our Code of Conduct (within our staff handbook). This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
4. Safeguarding policy – on identifying and responding to concerns regarding the safeguarding and protection of children, young people and vulnerable adults.

Hawk Training operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on-site audits which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
4. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
5. We may terminate the contract at any time should any instances of modern slavery come to light.

We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain as part of our Prevent / British Values and Safeguarding.

7.0 Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

1. No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
2. Our internal and external funders audits are at a low risk including checks of our suppliers Approval for this statement

This statement was approved by the Board of Directors on 01/08/2022

Crawford Knott

Managing Director